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PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION AND WE HAVE RECENTLY UPDATED IT. BY USING OUR SERVICES AND/OR ACCESSING OUR WEBSITE YOU ARE SIGNIFYING THAT YOU ARE AGREEING TO THIS PRIVACY POLICY AND AGREEING THAT YOUR PERSONAL INFORMATION WILL BE HANDLED AS DESCRIBED IN THIS POLICY. YOUR USE OF THE SITE AND ANY DISPUTE OVER PRIVACY ARE SUBJECT TO THIS POLICY AND TO THE TERMS OF USE TO WHICH THIS POLICY IS LINKED (AND MAY BE FOUND HERE).

Last Updated: April 11, 2024

As a company involved in assisting healthcare professionals and associated administrative staff with filing insurance claims and appeals, Covered Health Inc (“Covered”, “us”, “we”, “our”) stores and processes a great deal of personal data on behalf of our users. We understand that the privacy of our user’s information is important. Covered is committed to privacy, protecting such personal data, and being transparent about how we use, share, and protect such information. To further this commitment, Covered developed this privacy policy (“Privacy Policy”) to allow our users to better understand the types of information we collect, why we collect it, how we will use it, and the various options users have to manage the privacy of their information.

Scope of the Privacy Policy.

The Privacy Policy describes Covered’s privacy practices for the collection, use, and disclosure of the personal information that we collect in our usual course of business, including through our services, sites, products, desktop applications, and software (collectively, “Services”), and other initiatives such as marketing and product trainings.

In addition to the Privacy Policy, we may provide additional “just-in-time” disclosures or additional information about the data collection, use, and sharing privacies of those specific Services. These notices may supplement or clarify our privacy practices or may provide users with additional choices about how we will process their personal information.

The Privacy Policy applies to those that visit our website and purchase and/or use our Services. The Privacy Policy does not apply to other companies and individuals, including products or sites that may be displayed or linked to on our website or other Services. Such companies and individuals may have separate privacy policies and procedures; Covered is not responsible for such policies and procedures.

Responsible Entity.

Unless otherwise provided in the Privacy Policy, Covered is the controller of data and information as herein described.

1. INFORMATION COLLECTED BY COVERED

The information we receive depends on the context of how a user interacts with us, how their account is configured, and choices that users make, including privacy settings. Such information includes, but is not limited to, identification information, employment related information, financial information, health information, insurance information, and information regarding internet activity, preferences, and behaviors. Most personal identification information and other data we collect comes directly from our users. This occurs when users interact with our Services, such as registering on our website, filing claims, making appeals, and agreeing to receive marketing information. Also, when a user interacts with our Services, including using our website, we use Cookies (as defined below) to collect information about them and their systems and use of our Services. Additionally, the information provided to us or obtained from Cookies is combined with other information that may come from third parties. Below we will describe a high-level view of the various sources of personal data that we receive.

Information Users Provide Us.

By using the Services or contacting us in other ways, we may collect and process the following types of information:

  • Account Information. When anyone creates an account with Covered or downloads certain content, we are provided with and collect information that allows us to set up or open the account. This information may include but is not limited to names, addresses (physical and electronic), ages, pictures, phone numbers, IDs, passwords, password hints, insurance information, billing information, location and other information that identifies an individual personally.

  • Identification Information. Covered also collects information to verify its user’s identity, which may include but is not limited to name and social security number.

  • Health and Claim Information. When a user accesses or uses Covered’s Services, we receive information. This information may include but is not limited to invoices, statements, health information, insurance information, financial information, and information regarding user’s preferences. Such information may include information that is protected by law, including but not limited to the applicable provisions of the Health Insurance Portability and Accountability Act of 1996, as amended, and regulations promulgated thereunder (“HIPAA”). We may request a signature authorizing access to necessary Protected Health Information (“PHI”) in order to perform the claims and appeals services we provide.

  • Information Submitted to Covered. Covered offers its users the option to submit data to Covered. Such data may include pictures, documents, and other files.

  • Support, Feedback, and Requests. When a user reaches out to Covered for support, gives feedback, participates in surveys, uses beta services, requests additional information, or participates in trainings, we may also collect information.

  • We may also collect personal information if you contact us using our careers form or share your resume with us via email, your contact details, your CV and any additional information provided by you. Please be aware that the information that we infer or generate from other data collected in accordance with this paragraph will be collected on an aggregate or de-identified basis and will not be considered as “personal information”.

By providing us with any information, you represent and warrant that you have obtained all consents and authorizations required under any applicable federal and state law to share such information with us on behalf of the applicable data subjects and on behalf any company, business or establishment for which the Services are procured hereunder.

Information We Obtain From Users’ Access and Use.

When users access or use our Services, including accessing or using our website, and communicate with Covered, we may automatically collect certain information from different sources about them and how they use the Services. Such information may include:

  • Content Collection. Covered may collect content that users provide through the Services, such as personal information including names, usernames, mailing addresses, telephone numbers, email addresses, and account information; information about their working relationships and job titles; information about their health and health insurance; content provided to customer support; and other feedback users provide regarding the Services.

  • Usage Information. Covered may collect usage information from users including information regarding pages they have viewed, the features used, browser types, time spent on web pages, what data and files have been downloaded, and any links clicked on to leave or interact with our Services and additional information relating to how you interact with our website and the Services provided therein.

  • Information Regarding Devices. Covered may collect device information such as Media Access Control (MAC) address, Internet Protocol (“IP”) address, operating system name and version, browser type, log information, error messages, device type, network type, and unique device identifiers.

  • Location Information. Certain Service features may collect users’ precise location data, device motion data, or both, if a user grants permission to do so in their device settings.

  • Camera and Contacts. Certain Service features may have access to users’ camera and contacts, if a user grants permission to do so in their device settings.

  • Phone Calls. Anyone who communicates with Covered by phone may be monitored and/or the call may be recorded.

  • Telephony log information. If a user accesses certain features on a mobile device, Covered may collect telephony log information (e.g. phone numbers, time and dates of calls, duration of calls, and types of calls), device event information (e.g. crashes, hardware settings, and system activity), and location information (e.g. IP addresses and GPS).

  • Local Storage. Covered may collect and store information (including personal information) locally on user’s devices.

  • Cookies. Covered and our service providers may use commonly-used tools such as cookies, web beacons, server logs, pixel tags, browser analysis tools, local shared objects, and similar technologies (collectively, “Cookies”) to provide the Services requested, recognize visitors, track interactions with our Services, and improve user’s experience. By way of example, when a user visits our website, we place Cookies on their computer which allow us to recognize them upon their return. This permits Covered to provide a more customized experience as well as enables us to detect certain types of fraud. By way of a separate example, pixel tags and web beacons are small graphic images contained on web pages and in emails that allow Covered to determine whether a person has performed a specific action. For instance, when a person accesses a page or clicks on an email, the pixel tag or web beacon generates a notice. This allows Covered to measure responses and improve our Services and business operations. In general, Cookies provide Covered with a broad range of information including information regarding our user’s devices, operating systems, browser type, domain, system setting, system language uses, time zone/physical location, IP address, websites visited prior to coming to our website and websites visited after leaving our website. Users have some control over the data we collect from Cookies and how we use it. For more information about cookies see http://www.allaboutcookies.org.

 

As part of your website usage, we may share such personal information with third parties as further described below.

Information From Third Parties.

Covered may also receive information about our users from third parties (including analytics and tracking) where permitted by applicable law. Such third parties may include:

  • Parties with whom a user has an account or receives a service when they choose to sync that third-party account/service with their Covered account or integrate their data from that third party into the Service we provide.

  • Parties who help Covered to supplement the information a user has provided and to ensure the accuracy of such information.

  • Parties who provide Covered with information about users or users’ interaction with our Services.

  • Parties who provide us with support services.

  • Parties that provide us with risk management, cybersecurity, and anti-fraud services.

  • Joint offering partners.

  • Publicly available sources, such as government databases, and government agencies.

  • Our social platforms, advertising partners and publicly available sources, as well as other third parties who perform functions on our behalf and who also provide services to us, as further elaborated below.

To the extent permitted by law, such information from third parties may be combined with information provided by or obtained directly from users.

 

We may also collect other and additional information, with your permission.

Please be aware that you are not legally required to provide us with any information and any information will be provided by you voluntarily and at your discretion.

 

Notice to Users.

We may disclose personal information to our affiliates and third-party processors as needed to provide the requested services and as required by law, such as in response to a subpoena.

Required Information.

Some of the functionalities in our Services may require certain information to be provided in order to use the Services. A user may not be able to use certain features of the Services if they do not wish to provide such information.

2. HOW COVERED USES INFORMATION.

Covered uses user information, including in some instances PHI, in a variety of ways including in combination with other information that we may collect about you and information from third parties, each being part of Covered’s business purpose. Such uses include the following:

  • To provide, initiate, improve, protect, develop, and deliver the Services and our website, including to personalize experience, provide support, and to protect the security and safety of the Services, our users, Covered, the data that we maintain, and others, and to otherwise operate our business, including management, training, reporting, assessment, and analysis activities.

  • To communicate with our users, including to provide information regarding our Services or user accounts and to offer products and services (including third-party products and services), respond to your requests or inquires and expand business relationships, including marketing services, investor communications, user communications (e.g. alerts, updates, trainings, and invitations), and surveys.

  • To perform due diligence regarding an individual’s qualifications and eligibility, including verifying such a person’s identity, qualification, authority, and creditworthiness and obtaining publicly available information from third parties.

  • To analyze our users’ information and better understand how users access and use the Website (both on an aggregated and individualized basis), using both manual and automated systems, in order to assess and improve our Services, perform quality control, personalize our user’s experience, automate certain functions, aggregate and de-identify certain information, provide features, perform risk management, and to protect the safety and security of the Services, our users, Covered, and others.

  • To send transactional communications, including requests for information, responses, orders, confirmations, training, and updates.

  • To send marketing communications including information on our products and Services, subject to your consent.

  • To manage accounts, perform accounting and finance tasks, perform risk mitigation services (including internal and external audits and investigations), perform compliance functions, and for dispute resolution purposes, in any case of dispute, or legal proceeding of any kind, between you and us concerning our Services and website or your use thereof.

  • To enforce, remedy, or apply our agreements.

  • To license and protect intellectual property and other assets.

  • To perform business structure activities, including mergers, acquisitions, and divestitures.

  • To perform disaster recovery and business continuity services.

  • To perform research.

  • To determine a person’s eligibility for offers, products, and services.

  • For legal, compliance, and insurance purposes.

  • To identify and prevent unauthorized or prohibited use of our website, viruses, fraud or violation of our Terms of Use, the Privacy Policy or any applicable law.

Generally, Covered will only use a user’s collected personal information in the manner described in the Privacy Policy or for the purposes we designate at the time we collect such information. Notwithstanding the foregoing, to the extent permitted by law, Covered may use personal information for other purposes which are not incompatible with our business purposes and which are permitted by applicable law. To the extent required by law, Covered will provide users with further information on any such additional use when it happens.

Your consent serves as the legal basis for processing the information you provide. You may withdraw your consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.

3. HOW COVERED SHARES INFORMATION.

Covered may occasionally need to share information provided by users and information that we collect, including personally identifiable information, with third parties worldwide. However, Covered will only share such information as follows:

  • With our user’s consent (e.g. as part of a testimonial).

  • To provide the Services and to otherwise operate our business.

  • For joint sales, promotions, and events.

  • For legal reasons, such as if we reasonably believe disclosure is required or permitted by law, to enforce our agreements (including debt collection), or to protect the rights, property, or safety of Covered, the Services, our users, or others.

  • With our subsidiaries and affiliates.

  • With our service providers who provide services on our behalf and as we have instructed (e.g. IT services, hosting, credit card processing, research and analytics, marketing, and customer support). We will only provide these entities with the information necessary for them to perform the services on our behalf. These entities are contractually required to protect your personal information from unauthorized access, use, or disclosure.

  • In the event that Covered is a party to a merger, acquisition, asset sale, financing, liquidation, or bankruptcy, Covered may share user information before and after the transaction date.

  • With professional advisors acting as our service providers (e.g. lawyers, bankers, auditors, and insurers).

Please note, Covered does not permit our third-party service providers to use the personal information we share with them for their marketing purposes or for any other purpose other than in connection with providing services to Covered.

Notwithstanding the foregoing, Covered has no duty to disclose such information and therefore shall not be liable to users in connection with any nondisclosure.

4. PROCESSING USER INFORMATION.

Covered’s legal basis for collecting and using the information described in the Privacy Policy depends on the type of information and the specific context in which we collect it. Covered will normally collect user information from where the user has consented, where we need the information to perform a contract with the user, or where the processing is in our legitimate interests and not overridden by user’s data protection interests or fundamental rights and freedoms. Additionally, Covered may have a legal obligation to collect information from its users. If a user has any questions regarding the legal basis on which Covered collects and uses information, please contact us using the contact details provided below.

5. HOW USERS CAN MANAGE THEIR PRIVACY.

Users have choices when it comes to managing their privacy. Such rights include:

  • Updating their preferences, including opt-ins and opt-outs of marketing communications. To update preferences users can:

    • Email: Tal@CoveredHealth.ai

    • Click “unsubscribed” at the bottom of any Covered email;

    • Send “STOP” in response to any text message; or

    • Ask to be added to our “Do-Not-Call” list.
      Please note, if an individual is currently receiving services from Covered and decides to opt-out of promotional emails, it will not impact messages Covered sends for purposes of performing such services

  • In many cases a user can change browser settings to opt out of Cookies and other data collection technologies. Please note, disabling Cookies and opting out of data collection may cause partial or permanent interruption of the Services.

6. PERSONALLY IDENTIFIABLE INFORMATION.

Generally, information collected from Cookies is used in non-identifiable ways and without reference to any user’s personal data. By way of example, we may use such information to optimize our website and understand traffic patterns. In some instances, however, information collected from Cookies will be coupled with the user’s personal data. In those instances, the Privacy Policy applies to such associated information. In an effort to preserve our user’s privacy, Covered agrees that it will treat any personally identifying information that users submit through Covered’s Services in accordance with the terms outlined in the Privacy Policy.

7. DATA ACCURACY AND RETENTION.

Covered will use reasonable measures to keep user’s data accurate, complete, and up-to-date for purposes of providing services. However, in many cases Covered will rely on our users to use their own ability to access and correct such data to ensure its accuracy.

Covered will retain user information for so long as Covered deems necessary for purposes of maintaining accounts, providing Services, and for our business purposes. Such time period may vary depending on the amount, nature, and sensitivity of the particular data. Generally, after a user terminates their account or otherwise ceases to use the Services (including if we determine your account is inactive), Covered will no longer retain such user’s information except as follows:

  • To send marketing communications in accordance with such user’s marketing preferences, as detailed above;

  • For our legal or regulatory compliance; to exercise, establish or defend legal claims; and to protect against fraudulent or abusive activity on our service;

  • For general product improvement purposes in accordance with the Privacy Policy, provided that any data retained for this purpose will be used only for a limited period and handled securely and in confidence.

If Covered no longer needs a user’s information for the above purposes, we will generally delete or de-identify it in accordance with our standard data retention practices. However, there may be occasions where we are unable to fully delete or de-identify information due to technical or other operational reasons. If this occurs, Covered will take reasonable measures to securely isolate such information from any further processing until such time as we are able to delete or de-identify it.

8. THIRD-PARTY SERVICES, LINKS, AND INTEGRATIONS.

Third-party products, services, and applications may use or integrate with Covered’s Services, or otherwise be offered through our Services (“Third-Party Services”). If a user chooses to use any Third-Party Services or link or sync any of these Third-Party Services with their Covered account, such party is permitting Covered to provide their information and any information associated with their account to the third party. For purposes of clarification, a user’s interactions with Third-Party Services are governed by the privacy policy of the company providing such services.

Additionally, Covered may use advertising networks and other third parties to display advertisements within the Services or to manage our advertisements on other sites. Such third parties may place Cookies in the Services and unaffiliated websites, as well as on users’ devices in order to serve advertisements that may be relevant to our users based on browsing activities and interests, and to determine the effectiveness of such advertisements. While the Privacy Policy does not apply to such third parties, we do expect our third-party advertising companies to use reasonable efforts to respect our user’s choices regarding the use of Cookies. We encourage each user to familiarize themselves with the privacy statements provided by third parties prior to providing them with information or using their services.

If a person wishes to opt out of interest-based advertising, they may visit Digital Advertising Alliance’s Network Advertising Initiative’s website at https://www.networkadvertising.org/. Please note, even if you opt out of Cookies or otherwise opt out of interest-based advertising, you will still receive advertisements, however they will not be tailored to your interests. Additionally, please note if you opt out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew you opt-out choices.

9. SECURITY.

Covered understands the importance of security of information, particularly PHI, and will provide commercially reasonable administrative, physical, technical, and organizational security controls and safeguards. Additionally, Covered will only authorize access to user information to the extent necessary to serve its applicable business purposes, and Covered staff will access such information subject to confidentiality obligations. These are designed to prevent unauthorized use, access, processing, destruction, alteration, or disclosure of our user’s information. However, even with our best efforts, Covered cannot ensure or warrant the security of any information and no data security measures can guarantee 100% security. Accordingly, Covered shall not be liable for unauthorized disclosure of personal information due to no fault of Covered including, but not limited to, errors in transmission and unauthorized acts of third parties.

Additionally, there are steps that each user should take to protect themselves and their organization. Such steps include:

  • Choosing strong passwords, not sharing passwords, and periodically changing passwords.

  • Logging out of Services when they are not in use.

  • Not sharing devices that are used to access the Services.

  • Using fingerprint or facial recognition if your device has such features.

  • Reviewing Covered email reminders, such as log-in notices.

  • Monitoring for fake emails (please note, Covered will never ask a user for a password in an unsolicited phone call or email and our emails will always come from an email address that ends with @CoveredHealth.ai.

  • Avoiding customer support scams (please note, Covered will not reach out to you to fix problems with your computer).

  • Notify us immediately if information related to your payments (e.g. login information or credit cards) are lost or stolen.

Covered make best efforts to investigate all known or suspected security breaches and shall document the facts relating thereto, their effects, and remedial actions taken. Covered will also notify a user upon becoming aware of a material incident that has actually compromised the security, confidentiality, or integrity of their information as required by applicable law.

10. INTERNATIONAL DATA TRANSFERS.

At this time, Covered is headquartered in the United States of America, with R&D Headquarters located in Israel.

We may transfer certain information to other countries, which may not have an equivalent level of data protection as in your state. However, please rest assured that we implement all the necessary and appropriate legal, organizational and technical measures to protect your personal information. Your data also may be subject to access by law enforcement and other government entities, including courts and tribunals in accordance with the laws applicable in those jurisdictions.

11. HOW TO CONTACT US.

Please contact us if there are any questions or comments about the Privacy Policy or our practices, as follows:

  • Phone: 914-407-2382

  • Email: Tal@coveredhealth.ai

  • Mail: Covered Health Inc
    Attention: Privacy
    418 Broadway Ste R

      Albany NY 11207-2922

If you send a letter, please provide your name, address, email address, and detailed information about your question or comment.

12. HOW TO MAKE A COMPLAINT.

If any user believes its personal information has been provided to Covered improperly by a third party or Covered has not handled their information properly or has breached its privacy obligations, either under any agreement between Covered and such user, the Privacy Policy or applicable law, such party can file a complaint in writing to the address listed above under “How to Contact Us” or via email to Tal@CoveredHealth.ai

Covered will use reasonable efforts to investigate each complaint and notify such user within a reasonable timeframe of the outcome of such investigation.

13. CHANGES TO OUR PRIVACY POLICY.

Covered reserves the right to make changes or updates to the Privacy Policy at any time and from time to time, so please be sure to check it back periodically. If material changes are made, we will provide you with notice via the Services or by other communication channels, such as by email, and by posting such new Privacy Policy on our website and making it available via our app. Please review any changes carefully.

14. COLLECTION AND USE OF CHILDRENS’ PERSONAL INFORMATION.

The Services are intended for and directed to persons eighteen (18) years of age or older, or nineteen (19) years of age or older for persons residing in Alabama or Nebraska, or twenty-one (21) years of age or older for persons residing in Mississippi. Covered does not knowingly provide Services to minors.

15. ACCESSING AND CORRECTING INFORMATION.

Covered respects its users’ rights to access, correct, and delete their information and update their information if it is incorrect. Users who have registered accounts can log into their account to access, review, update, or delete the information provided to us to the extent permitted by law. Additionally, to the extent permitted by applicable law, parties may contact tal@Coveredhealth.ai to request access to their data and to exercise any other individual rights afforded to them by the Privacy Policy or applicable data protection laws. Notwithstanding the foregoing, Covered will also seek to protect other individuals’ rights as required by law.

As permitted by applicable law, we may retain changed or deleted information for archival purposes. If you wish to view, correct or delete your personal information please contact us using the contact information detailed below.

 

You represent and warrant that you have made all applicable disclosures to the persons whose information you share with us and have informed such persons with respect to their rights, all to the extent required by federal and state law applicable to such persons.

16. PERSONAL RIGHTS WITH RESPECT TO DATA.

Some data protection laws, including those of specific states, provide individuals with certain rights in connection with their personal data. Such rights may generally include:

  • The right to be informed with how your data will be used. The Privacy Policy provides such information.

  • The right to access a copy of your data. Section 15 provides details regarding making such requests.

  • The right to request changes to data if the information is incorrect. Section 15 provides details regarding making such requests.

  • The right to have data deleted when it is no longer necessary for Covered to retain such data. Sections 5, 7, and 15 provide details regarding this process.

  • The right to opt out of certain uses of your data at any time. Sections 5 and 8 provide details regarding this process.

  • The right to have a portable copy of your data. Section 15 provides details regarding making such requests.

  • The right to refuse to be subjected to automated decision making and insist on human intervention. The Privacy Policy provides multiple means for users to communicate directly with Covered personnel, including those listed in Sections 11 and 12.

  • The right to lodge a complaint with a supervisory authority. Section 12 provides details regarding making such a complaint.

Additionally, depending on the state in which you live, you may have certain state-specific legal rights with respect to your personal information and how it is collected and processed.

Nevada Privacy Rights.

Covered collects personal information from our users in the course of providing requested services. Unless otherwise stated, Covered does not sell any Covered Information, as defined under Nevada law (S.B. 220). If any user of the Services would like to make further inquiry regarding the selling of their Covered Information as defined under Nevada law, please contact Tal@CoveredHealth.ai

California “Do Not Track” Disclosures.

While some internet browsers offer a “Do Not Track” option that lets you tell websites if you want to have your online activities tracked, Covered is not currently configured to monitor, recognize or respond to browsers’ “Do Not Track” signals at this time as no form “Do Not Track” standard has been adopted. Accordingly, Covered does not currently commit to monitoring, recognizing, or responding to browsers’ “Do Not Track” signals with respect to our website, but will continue to monitor developments around such technology and the implementation of such standards.

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